Privacy Policy
Providence Capital Group LLC
Effective Date: March 17, 2026 – Version 1.0 – Last Reviewed: March 2026
PRIVACY NOTICE — This Privacy Policy describes the personal information that Providence Capital Group LLC and its affiliated entities (collectively, "Providence Capital Group," "PCG," "we," "us," or "our") collect through our website at www.providencecapitalgroup.com (the "Site"), how we use and share that information, and the rights and choices available to you. Please read this Policy carefully. By accessing or using the Site, you agree to the collection, use, and disclosure of your information as described herein.
1. Scope & Applicability
This Privacy Policy applies to personal information collected through the Site, including publicly accessible pages, password-protected investor portals, contact and inquiry forms, and any other digital touchpoints operated by Providence Capital Group in connection with its business activities.
This Policy applies to the following categories of individuals ("Data Subjects") whose information we may collect:
Visitors and users of the Site, including prospective investors, financial intermediaries, and members of the public;
Current and prospective limited partners, co-investors, and fund subscribers of Providence Capital Groups affiliated fund strategies;
Employees, officers, and beneficial owners of institutional counterparties, lenders, joint venture partners, and service providers;
Individuals who contact us through the Site or by email, telephone, or other means.
This Policy does not apply to personal information collected through offline channels, employment applications, or information governed by separate contractual agreements (such as subscription documents or investor access agreements), except to the extent such information is processed in connection with the Site.
2. Information We Collect
We collect personal information from multiple sources, including directly from you, automatically through your use of the Site, and from third parties. The categories of information we may collect include:
A. Information You Provide Directly
Identification and contact information: full name, title, employer or organization, email address, telephone number, and mailing address;
Investor qualification information: accredited investor status, qualified purchaser status, net worth, annual income, investment experience, and related certifications;
Know Your Customer ("KYC") and Anti-Money Laundering ("AML") documentation: government-issued identification, beneficial ownership information, tax identification numbers, and supporting verification materials;
Correspondence and communications: the content of emails, messages, or other communications you send to us through the Site or otherwise;
Event and meeting information: registration details and preferences submitted in connection with investor days, conferences, or site visits.
B. Information Collected Automatically
Device and browser information: IP address, browser type and version, operating system, device identifiers, and screen resolution;
Usage and navigation data: pages visited, links clicked, time spent on pages, referring URLs, and navigation paths through the Site;
Cookie and tracking data: session identifiers, preference cookies, and analytics data collected through cookies and similar technologies (see Section 6);
Log data: server logs recording access requests, error logs, and related technical data.
C. Information from Third Parties
Due diligence and verification providers: identity verification, background screening, sanctions screening, and politically exposed persons ("PEP") database checks;
Data aggregators and public sources: publicly available financial and professional information from regulatory filings, corporate registries, press releases, and similar sources;
Referral partners and intermediaries: contact and relationship information provided by wealth managers, registered investment advisers, placement agents, or other intermediaries who refer prospective investors to us;
Analytics and technology providers: aggregated or pseudonymized data enriching our understanding of Site traffic and user behavior.
3. How We Use Personal Information
We use personal information collected through the Site for the following purposes, in each case relying on one or more of the legal bases described in Section 9:
Investment and Business Operations
Evaluating and processing requests from prospective investors and counterparties, including conducting investor qualification reviews and suitability assessments;
Administering and managing investor relationships across Providence’s affiliated fund strategies
Maintaining and updating investor records, contact information, and documentation.
Compliance and Legal Obligations
Conducting KYC, AML, OFAC sanctions screening, and other regulatory due diligence as required under applicable law;
Complying with requirements under the Bank Secrecy Act, the USA PATRIOT Act, the Foreign Account Tax Compliance Act ("FATCA"), the Common Reporting Standard ("CRS"), and other applicable federal, state, and international regulations;
Responding to lawful requests from regulatory authorities, courts, law enforcement agencies, and other governmental bodies;
Retaining records in accordance with applicable legal and regulatory retention requirements.
Communication and Relationship Management
Responding to inquiries, information requests, and investor correspondence submitted through the Site;
Delivering investor communications, fund newsletters, quarterly updates, annual reports, and capital account statements to current limited partners;
Providing information about investment strategies, fund offerings, and market insights to prospective investors and intermediaries, where permitted by applicable law;
Sending administrative notices, including updates to these policies, system notifications, and security alerts.
Site Operations and Security
Operating, maintaining, and improving the Site and its features and functionality;
Monitoring Site security, detecting and preventing fraud, unauthorized access, and malicious activity;
Conducting analytics and performance monitoring to understand how the Site is used and to enhance user experience;
Troubleshooting technical issues and errors.
4. Disclosure of Personal Information
We do not sell, rent, or trade personal information to third parties for their own marketing purposes. We may share personal information in the following limited circumstances:
A. Service Providers and Vendors
We engage third-party service providers who process personal information on our behalf and under our instruction in connection with fund administration, investor portal technology, legal and compliance services, accounting and audit, KYC/AML verification, data storage and cybersecurity, and communications platforms. Such providers are contractually bound to use personal information only for the purposes specified by us and to maintain appropriate security standards.
B. Fund Affiliates and Joint Venture Partners
We may share personal information with affiliated funds and entities within the Providence Capital Group family, including entities associated with Providence’s fund strategies well as with joint venture partners and operating partners where necessary to manage investment activities, coordinate asset operations, or fulfill contractual obligations.
C. Legal and Regulatory Authorities
We may disclose personal information to regulatory authorities, law enforcement agencies, courts, arbitral tribunals, or other governmental bodies where required or permitted by applicable law, including in response to subpoenas, court orders, regulatory examinations, or other legal process.
D. Lenders and Financial Counterparties
We may share personal information with lenders, institutional counterparties, or financial institutions in connection with financing transactions, including as may be required under loan documents or co-investment agreements. Disclosure to lenders may include beneficial ownership certifications and related KYC documentation as required under applicable regulations.
E. Professional Advisors
We may share personal information with our legal counsel, accountants, auditors, tax advisors, and other professional advisors who are bound by professional confidentiality obligations.
F. Business Transfers
In the event of a merger, acquisition, reorganization, recapitalization, sale of assets, or other business combination involving Providence Capital Group or any of its affiliated funds, personal information may be transferred to the successor entity as part of such transaction, subject to confidentiality protections consistent with this Policy.
G. With Your Consent
We may share personal information with third parties for any other purpose with your express prior consent.
5. Data Retention
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with applicable legal, regulatory, and contractual obligations, and to resolve disputes or enforce our agreements. The specific retention periods applicable to personal information we collect depend on the nature of the information and the context in which it was collected, and may include:
Investor and counterparty records: for the duration of the investment relationship and for a minimum of seven (7) years following the final distribution or liquidation of the applicable fund, consistent with SEC, FinCEN, and IRS recordkeeping requirements;
KYC and AML documentation: for a minimum of five (5) years following the end of the business relationship, or longer as required by applicable law;
Correspondence and communication records: for a period of up to seven (7) years, or longer where relevant to pending or threatened litigation;
Site usage and analytics data: for up to twenty-four (24) months from the date of collection, subject to applicable law;
Cookie and tracking data: in accordance with the retention periods disclosed in our Cookie disclosure (see Section 6).
When personal information is no longer required, we will securely delete or anonymize it in accordance with our data retention and destruction procedures.
6. Cookies & Tracking Technologies
We use cookies and similar tracking technologies (collectively, "Cookies") to operate and improve the Site, to understand how users interact with our content, and to deliver a more personalized experience to returning visitors. The types of Cookies we may use include:
Strictly Necessary Cookies: Required for the Site to function and cannot be disabled. These include session authentication Cookies for the investor portal and security tokens;
Performance and Analytics Cookies: Used to collect aggregated information about how visitors use the Site, including pages visited, time spent, and error reports. We may use third-party analytics providers such as Google Analytics for this purpose;
Functional Cookies: Allow the Site to remember your preferences, such as language settings or previously completed forms, to provide enhanced functionality;
Targeting and Marketing Cookies: May be used to deliver content relevant to your interests and to measure the effectiveness of our communications. We do not use targeting Cookies for general advertising purposes, given the nature of our business.
Most web browsers allow you to manage your Cookie preferences through browser settings. You may choose to disable non-essential Cookies; however, doing so may affect the functionality of certain portions of the Site, including the investor portal. Where required by applicable law, we will seek your consent before placing non-essential Cookies.
7. Data Security
Providence Capital Group implements a risk-based information security program designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. Our security measures include, without limitation:
Encryption of personal information in transit using Transport Layer Security (TLS) protocols, and encryption at rest for sensitive data stored in our systems;
Access controls, including role-based access restrictions, multi-factor authentication for investor portal access, and least-privilege principles governing system permissions;
Regular security assessments, penetration testing, and vulnerability management procedures;
Vendor security due diligence, including contractual security requirements for third-party service providers that process personal information on our behalf;
Employee training on data protection obligations and information security best practices;
Incident response procedures designed to detect, contain, and notify affected parties of data security incidents in accordance with applicable law.
Notwithstanding the foregoing, no security system is impenetrable, and we cannot guarantee that unauthorized parties will never be able to circumvent our security measures. You acknowledge that any transmission of personal information to us is at your own risk. If you believe your personal information has been compromised, please contact us immediately using the contact details in Section 13.
8. International Data Transfers
Providence Capital Group is headquartered in the United States and operates primarily within the United States. Personal information collected through the Site is stored and processed in the United States. If you access the Site from outside the United States, you acknowledge that your personal information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country of residence.
Where we transfer personal information of individuals located in the European Economic Area ("EEA"), the United Kingdom, or other jurisdictions with data transfer restrictions, we will implement appropriate safeguards, which may include Standard Contractual Clauses approved by the European Commission, reliance on adequacy decisions, or other legally recognized transfer mechanisms.
By using the Site, you consent to the transfer of your personal information to the United States as described in this Policy.
9. Legal Bases for Processing (EEA & UK Users)
To the extent we process personal information of individuals located in the European Economic Area or the United Kingdom, we rely on one or more of the following legal bases under the General Data Protection Regulation ("GDPR") or applicable UK data protection law:
Contractual necessity: Processing is necessary to perform our obligations under a contract with you or to take steps at your request prior to entering into a contract (e.g., processing investor subscription applications);
Legal obligation: Processing is necessary to comply with applicable law (e.g., KYC, AML, tax reporting, and regulatory recordkeeping requirements);
Legitimate interests: Processing is necessary for our legitimate business interests, including operating the Site, maintaining investor relationships, detecting fraud, and managing risk, provided such interests are not overridden by your rights and interests;
Consent: Where we rely on consent as a legal basis, you have the right to withdraw your consent at any time by contacting us using the information in Section 13.
10. Your Privacy Rights
Depending on your jurisdiction of residence, you may have certain rights with respect to your personal information. These rights may include:
Right of access: The right to request confirmation of whether we process your personal information and, if so, to obtain a copy of that information;
Right to rectification: The right to request correction of inaccurate or incomplete personal information we hold about you;
Right to erasure: The right to request deletion of your personal information, subject to applicable legal and regulatory retention obligations;
Right to restriction of processing: The right to request that we limit our processing of your personal information in certain circumstances;
Right to data portability: The right to receive your personal information in a structured, commonly used, machine-readable format, where technically feasible and where processing is based on consent or contract;
Right to object: The right to object to our processing of your personal information where we rely on legitimate interests as our legal basis;
Right to opt out of sale or sharing: Residents of California and certain other U.S. states may have the right to opt out of the sale or sharing of personal information for cross-context behavioral advertising purposes. We do not sell personal information as defined under applicable U.S. state privacy laws.
To exercise any of these rights, please submit a written request to us using the contact information provided in Section 13. We will respond to verifiable requests within the timeframe required by applicable law (generally within thirty (30) to forty-five (45) days). We may require you to verify your identity before we can process your request. Please note that certain rights are subject to limitations and exceptions under applicable law, including where processing is required to fulfill legal obligations or where data is subject to professional secrecy obligations.
11. U.S. State Privacy Disclosures
We make the following additional disclosures for residents of states with applicable consumer privacy laws, including California (CCPA/CPRA), Colorado, Virginia, Connecticut, and other states with similar legislation.
Categories of Personal Information Collected
In the preceding twelve (12) months, we have collected the following categories of personal information from or about residents: identifiers (name, email, IP address); professional and employment information; financial information (investor qualification data); commercial information; internet or network activity information; and inferences drawn from the above to create a profile about a user’s preferences or characteristics.
Business or Commercial Purpose for Collection
We collect personal information for the business purposes described in Section 3 of this Policy, including fund operations, legal compliance, investor relationship management, and Site security.
No Sale of Personal Information
California "Shine the Light" Disclosure
California Civil Code Section 1798.83 permits California residents who have provided personal information to us to request information about our disclosures, if any, of personal information to third parties for their own direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.
12 Third-Party Links & External Services
The Site may contain links to external websites, data rooms hosted by third parties, or other online services that are not operated by Providence Capital Group. This Privacy Policy does not apply to any third-party websites or services. We encourage you to review the privacy policies of any third-party sites or services you access through or in connection with the Site.
We are not responsible for the content, privacy practices, or data security of any third-party websites or services, and our inclusion of a link to any third-party site does not constitute our endorsement of that site or its privacy practices.
13 Children's Privacy
The Site is not directed to individuals under the age of eighteen (18), and we do not knowingly collect personal information from minors. If you are under 18 years of age, you may not use the Site or submit any personal information through it. If we become aware that we have inadvertently collected personal information from an individual under 18, we will take prompt steps to delete such information from our records. If you believe we may have collected information from a minor, please contact us using the information in Section 14.
14 Amendments to This Policy
We reserve the right to modify or update this Privacy Policy at any time in our sole discretion to reflect changes in our information practices, legal requirements, or business operations. All amendments will be effective upon posting of the revised Policy to this Site, together with an updated "Effective Date." If we make material changes to this Policy, we may provide additional notice to affected individuals by email or through a prominent notice on the Site.
Your continued access to or use of the Site following the effective date of any revised Policy constitutes your acceptance of and agreement to be bound by such revised Policy. We encourage you to review this Policy periodically. The most current version will always be available at this URL.
15. Contact & Data Privacy Requests
For questions, concerns, or requests relating to this Privacy Policy or the processing of your personal information, please contact:
Providence Capital Group LLC
Attn: Legal & Compliance / Data Privacy
460 West 50 North, Suite 500
Salt Lake City, UT 84101
info@provcapgroup.com
For investor relations inquiries unrelated to data privacy, please contact: investors@provcapgroup.com
We will endeavor to respond to all privacy-related inquiries within thirty (30) days of receipt. Responses may be extended by an additional sixty (60) days where necessary, in which case we will notify you of the extension and the reason for the delay.
If you are located in the EEA or UK and are not satisfied with our response, you have the right to lodge a complaint with your applicable supervisory authority. In the United States, certain state residents may also have the right to appeal our response by re-contacting us and referencing the original request.